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Aviation Compliance — 14 CFR Part 145, Subpart D

Part 145 Personnel: The §145.161 Roster, the §145.163 Training Program, and Hazmat Records

A repair station's people are its certificate. This is a line-by-line guide to the four §145.161 rosters, the 5-business-day update rule, the FAA-approved §145.163 training program, the 2-year training-record floor, and the §145.165 hazmat training records an FSDO inspector cross-checks against your work orders.

Chad Griffith, Founder & CEOReviewed: June 13, 202613 min read

Compliance document perspective, not A&P or IA certification guidance. This article explains the personnel-records and training-records documentation requirements of 14 CFR Part 145, Subpart D — it is not a substitute for the judgment of a certificated A&P mechanic, IA, accountable manager, chief inspector, or aviation attorney on any specific qualification or training scenario.

HomeBlogAviation CompliancePart 145 Personnel — §145.161 & §145.163

The Short Answer

14 CFR §145.161 requires a certificated repair station to maintain and make available, in a format acceptable to the FAA, three rosters — management and supervisory personnel, inspection personnel, and personnel authorized to sign a maintenance release for return to service — plus an employment summary for each named individual showing they meet the Part 145 experience requirements. Those rosters must be updated to reflect terminations, reassignments, changes in duties or scope, and new personnel within 5 business days of the change.

Separately, §145.163 requires the station to have and use an FAA-approved employee training program of initial and recurrent training, document each employee's training in an FAA-acceptable format, and retain those training records for at least 2 years. And §145.165 layers on hazardous materials training obligations that flow from 49 CFR for stations that are hazmat employers or that support Part 121/135 hazmat functions. Together, these are the records that prove the people approving your work are who the certificate says they are — the first thing an FSDO inspector cross-checks against your signed work orders.

3 Rosters
Management/supervisory, inspection, and return-to-service
14 CFR §145.161(a)
5 Business Days
To update a roster after a personnel change
14 CFR §145.161(b)
2 Years
Minimum retention for employee training records
14 CFR §145.163(c)

Most of the public attention on Part 145 goes to the binder — work orders, 8130-3 tags, the quality control manual. But in a repair station, the people are the certificate. The authority to approve an article for return to service does not attach to the company; it attaches to named, qualified individuals whose names appear on a roster the FAA can demand on request. This article decodes 14 CFR §145.161 roster by roster, walks through the FAA-approved training program at §145.163, and explains how §145.165 hazmat training fits — then maps each requirement to the surveillance finding it prevents.

This post is a companion to FileFlo's coverage of the rest of the Part 145 records world. If you came here for the work-documentation side, see Part 145 repair station recordkeeping requirements and the Part 145 audit binder an inspector asks for. For the manual that ties the personnel rules together, see the Repair Station and Quality Control Manual (RSQCM).

The roster is evidence, not a formality

A repair station can employ excellent mechanics and still generate findings if the rosters are stale, an authorized signer is missing from the §145.161(a)(3) roster, or an employment summary does not actually demonstrate the experience the personnel rules require. When an inspector reads a signature on a work order, the very next question is "is this person on the authorized roster, and is their training current?" The roster and training file are how you answer it in seconds instead of scrambling.

14 CFR §145.161 Decoded: The Rosters and the Update Rule

The section is titled "Records of management, supervisory, and inspection personnel." It has two operative paragraphs: (a) defines what must be maintained, and (b) sets the deadline to keep it current. Here is what each requires and why it matters during a surveillance visit.

§145.161(a)

What the station must maintain

"A certificated repair station must maintain and make available in a format acceptable to the FAA the following: (1) A roster of management and supervisory personnel that includes the names of the repair station officials who are responsible for its management and the names of its supervisors who oversee maintenance functions. (2) A roster with the names of all inspection personnel. (3) A roster of personnel authorized to sign a maintenance release for approving a maintained or altered article for return to service. (4) A summary of the employment of each individual whose name is on the personnel rosters required by paragraphs (a)(1) through (a)(3) of this section."

1

Three rosters, not one combined list

§145.161(a) calls for three distinct rosters: management/supervisory (a)(1), inspection (a)(2), and return-to-service (a)(3). A single name can appear on more than one — a chief inspector who also holds return-to-service authority belongs on both the inspection and the return-to-service roster — but the FAA expects each list to be identifiable. The phrasing is "make available in a format acceptable to the FAA," which means the station controls the format but the FAA controls whether it is acceptable.

2

The employment summary — §145.161(a)(4) — is where the proof lives

A name on a roster is a claim. The employment summary is the evidence that the claim is true. §145.161(a)(4) requires a summary for each rostered individual that contains enough information to show compliance with the experience requirements of Part 145, and specifically must include:

  • Present title

    The individual’s current role at the repair station.

  • Total years of experience and the type of maintenance work performed

    Both the duration and the nature of the work — airframe, powerplant, avionics, components, etc.

  • Past relevant employment with names of employers and periods of employment

    Enough employment history to substantiate the experience claimed for the role.

  • Scope of present employment

    What the person is actually authorized and assigned to do at the station now.

  • The type of mechanic or repairman certificate held and the ratings on that certificate, if applicable

    Part 65 certificate type and ratings — required for U.S.-based supervisors and return-to-service signers under §145.153 and §145.157, captured here on the summary.

Common §145.161(a) finding

A name on the return-to-service roster with no employment summary, or a summary that lists a title and certificate but does not actually demonstrate the experience the role requires. A roster entry without backing evidence is treated as an unproven qualification — and if that person has been signing work orders, the finding reaches the work too.

§145.161(b)

The 5-business-day update rule

"Within 5 business days of the change, the rosters required by this section must reflect changes caused by termination, reassignment, change in duties or scope of assignment, or addition of personnel."

!

This is a hard, specific deadline, and it is one of the most commonly missed in Part 145 surveillance. Four trigger events start the 5-business-day clock: termination, reassignment, change in duties or scope of assignment, and addition of personnel. A promotion from technician to supervisor is a change in duties. Moving someone from one rating area to another is a change in scope. A new hire with return-to-service authority is an addition. Each must be reflected on the relevant roster within five business days — not at the next manual revision, not at the annual review.

The cross-check that catches stale rosters

An inspector pulls recent work orders and reads the approving signatures, then compares those names against the current return-to-service roster. A signer who is not on the roster, or a roster name who left months ago and was never removed, is a §145.161(b) finding — and a live signer who is not authorized is a far more serious problem than a clerical lag.

Why a static binder loses this fight

A roster kept as a printed page in a binder drifts the moment HR makes a change the chief inspector doesn't hear about. The shops that stay clean treat the roster as a living record tied to onboarding and offboarding, so a personnel change and the roster update happen as one event — which is exactly the discipline a document-tracking layer is built to enforce.

The personnel rules behind each roster name

The §145.161 rosters are the evidence layer. The qualification rules they prove sit just upstream in the same subpart:

  • §145.151 — the station must designate an accountable manager and provide qualified personnel to plan, supervise, perform, and approve work, with a sufficient number of trained employees, and must determine the abilities of its noncertificated employees based on training, knowledge, experience, or practical tests.
  • §145.153 — supervisory personnel: enough supervisors to direct the work; a U.S.-based supervisor must hold a Part 65 mechanic or repairman certificate; supervisors must understand, read, and write English.
  • §145.155 — inspection personnel: thoroughly familiar with the applicable regulations and the inspection methods, proficient with the inspection equipment and visual aids, and able to understand, read, and write English.
  • §145.157 — return-to-service personnel: a U.S.-based signer must be a Part 65 mechanic or repairman; a signer outside the U.S. must be trained in or have 18 months of practical experience plus regulatory familiarity; all such personnel must understand, read, and write English.

The Six Personnel Records a Surveillance Visit Touches

The §145.161 rosters do not stand alone — they connect to the employment summaries, the §145.163 training file, and the §145.165 hazmat records. Here is every personnel record that feeds a finding during a Part 145 surveillance inspection, including who belongs on it and the finding it prevents.

Management & Supervisory Roster

14 CFR §145.161(a)(1)

What's Required

A roster that includes the names of the repair station officials responsible for its management and the names of its supervisors who oversee maintenance functions. The qualification rule behind the supervisor entries is §145.153 (Part 65 certification for U.S.-based supervisors; English literacy for all).

Who Belongs On It

Accountable manager, responsible managers, and every supervisor overseeing a maintenance function.

Audit Finding Prevented

A person directing maintenance work who does not appear on the management/supervisory roster, or a roster name who has left or changed roles but was not updated within the §145.161(b) 5-business-day window.

Inspection Personnel Roster

14 CFR §145.161(a)(2)

What's Required

A roster with the names of all inspection personnel. The qualification rule behind these entries is §145.155 — inspectors must be thoroughly familiar with the applicable regulations and the inspection methods, proficient with the inspection equipment, and able to understand, read, and write English.

Who Belongs On It

Everyone the station authorizes to perform inspections, including required-inspection-item (RII) inspectors where applicable.

Audit Finding Prevented

An inspection signoff in the records traced to a person not on the inspection roster, or an inspector on the roster whose employment summary does not show the experience §145.155 requires.

Return-to-Service (Maintenance Release) Roster

14 CFR §145.161(a)(3)

What's Required

A roster of personnel authorized to sign a maintenance release for approving a maintained or altered article for return to service. The qualification rule is §145.157 — Part 65 certification for U.S.-based signers; 18 months of experience or equivalent training plus regulatory familiarity for signers outside the U.S.; English literacy in all cases.

Who Belongs On It

Every mechanic or repairman the station authorizes to approve articles for return to service.

Audit Finding Prevented

A work order or maintenance release signed by someone not on the authorized return-to-service roster. This is one of the highest-severity personnel findings because it puts the validity of the approval itself in question.

Employment Summaries

14 CFR §145.161(a)(4)

What's Required

A summary of the employment of each individual on the three rosters, containing enough information to show compliance with the experience requirements of Part 145, and including: present title; total years of experience and the type of maintenance work performed; past relevant employment with employer names and periods; scope of present employment; and the type of mechanic or repairman certificate held and its ratings, if applicable.

Who Belongs On It

Every named individual on the management/supervisory, inspection, and return-to-service rosters.

Audit Finding Prevented

A roster name with no employment summary, or a summary that does not actually demonstrate the experience the §145.151–§145.157 personnel rules require for that role. A name on the roster without backing evidence is treated as unproven qualification.

Employee Training Records

14 CFR §145.163(c)

What's Required

Documentation, in a format acceptable to the FAA, of the individual employee training delivered under the FAA-approved initial-and-recurrent training program required by §145.163(a). These training records must be retained for a minimum of 2 years.

Who Belongs On It

Each employee assigned to perform maintenance, preventive maintenance, alterations, and inspection functions.

Audit Finding Prevented

An employee who signed off work has a lapsed, incomplete, or missing training record. Generates both a §145.163 training finding and a shadow question over every affected work order.

Hazmat Training Records (if applicable)

14 CFR §145.165 + 49 CFR Part 172 Subpart H

What's Required

If the station is a hazmat employer under 49 CFR 171.8, a hazardous materials training program meeting 49 CFR Part 172, Subpart H. Separately, an employee may not perform or directly supervise a §121.1001 or §135.501 job function (including loading aircraft) for a Part 121/135 operator unless trained under that operator’s FAA-approved hazmat program (§145.165(b)).

Who Belongs On It

Hazmat employees as defined by 49 CFR, and any employee performing covered air-carrier hazmat functions.

Audit Finding Prevented

A station that ships regulated articles or supports air carrier hazmat functions cannot produce current hazmat training for the employees performing those functions. The applicability call is the station’s hazmat authority’s, not a document platform’s.

14 CFR §145.163: The FAA-Approved Training Program

A repair station does not get to write any training program it likes. §145.163 requires an FAA-approved program of initial and recurrent training, documented and retained. Here is the section, paragraph by paragraph.

§145.163

Training requirements

(a) The program must be FAA-approved and cover initial and recurrent training

"A certificated repair station must have and use an employee training program approved by the FAA that consists of initial and recurrent training. An applicant for a repair station certificate must submit a training program for approval by the FAA as required by §145.51(a)(7)."

The program is not optional and not self-certified — it is approved by the FAA, and a certificate applicant must submit it as part of the application under §145.51(a)(7). It must contain both initial training (when an employee starts or takes on a new function) and recurrent training (ongoing).

(b) It must make each employee capable of the assigned task

"The training program must ensure each employee assigned to perform maintenance, preventive maintenance, or alterations, and inspection functions is capable of performing the assigned task."

The standard is capability tied to the assigned task — training is mapped to what the person actually does, not a generic curriculum. This is the link between the training file and the rosters: the people on the inspection and return-to-service rosters need training appropriate to the functions those rosters authorize.

(c) Document the training and keep it at least 2 years

"A certificated repair station must document, in a format acceptable to the FAA, the individual employee training required under paragraph (a) of this section. These training records must be retained for a minimum of 2 years."

The record must be individual (per employee) and in an FAA-acceptable format, with a minimum 2-year retention. This 2-year clock is specific to training records and is independent of the station's maintenance-record retention under §145.219 (covered separately in the recordkeeping post). In practice, prudent shops keep training records for the duration of employment plus several years.

(d) Submit revisions through the §145.209(e) procedures

"A certificated repair station must submit revisions to its training program to its responsible Flight Standards office in accordance with the procedures required by §145.209(e)."

The repair station manual must contain procedures for revising the training program and submitting those revisions to the responsible Flight Standards office for approval — §145.209(e) is the manual provision that governs how training-program changes move through the FAA. You cannot quietly amend the approved program; the change follows the manual's revision process.

The training file and the roster are read together

The most damaging personnel finding is not a single lapsed certificate — it is the combination. When an employee who signed off a work order also has a lapsed or missing training record, the inspector raises a §145.163 training finding and a shadow question over the validity of the work that person approved. That is why the cleanest shops drive the roster, the employment summary, and the training file from one system instead of three disconnected binders.

§145.165

Hazardous materials training (if applicable)

§145.165 adds a conditional training obligation that reaches outside Title 14 into the hazardous-materials rules of Title 49:

§145.165(a) — hazmat employers

A repair station that meets the definition of a hazmat employer under 49 CFR 171.8 must have a hazardous materials training program that meets the requirements of 49 CFR Part 172, Subpart H.

§145.165(b) — air carrier hazmat functions

An employee may not perform or directly supervise a job function listed in §121.1001 or §135.501 for a Part 121 or Part 135 operator — including loading aircraft — unless that person has received training under that operator's FAA-approved hazardous materials training program.

The practical takeaway: not every repair station triggers §145.165, but a station that ships regulated articles, handles dangerous goods, or supports an air carrier's hazmat functions takes on training obligations that flow from 49 CFR — and the documentation has to exist for the specific employees performing those functions. Whether your station is a hazmat employer, and which functions are covered, is a determination for your hazmat authority and the operators you support; a document platform tracks the resulting certificates and their expirations, it does not make the applicability call. For the related cargo and dangerous-goods records, see will-not-carry records, will-carry program records, and supervisor training records.

What an FSDO Inspector Cross-Checks on Personnel

During repair station surveillance, an FSDO Principal Maintenance Inspector tends to follow a predictable path from the work back to the people who performed and approved it. Here is the order a personnel review typically takes and how to be clean at each step.

1

Roster currency check

The inspector asks for the three §145.161 rosters and reads them for currency. Recent hires, departures, promotions, and scope changes should already be reflected — the §145.161(b) deadline is 5 business days, so a change from last week that is not on the roster is a finding regardless of how good the underlying personnel are.

How to pass this step cleanly: Tie roster updates to onboarding and offboarding so a personnel change and the roster edit are one event. A roster that updates itself when HR acts never drifts past the 5-business-day window.

2

Signature-to-roster cross-check

The inspector pulls a sample of recent work orders and maintenance releases, reads the approving signatures, and verifies each signer appears on the §145.161(a)(3) return-to-service roster. A name approving articles who is not on the authorized roster is among the most serious personnel findings because it questions the approval itself.

How to pass this step cleanly: Maintain a single source of truth where the authorized-signer roster and the signed work orders can be reconciled on one screen. Any signer not on the roster should be impossible to miss.

3

Employment-summary substantiation

For the sampled roster names, the inspector checks the §145.161(a)(4) employment summary — present title, total experience and type of work, past employers and periods, scope of present employment, and certificate type and ratings — to confirm the summary actually demonstrates the experience the role requires under §145.151 through §145.157.

How to pass this step cleanly: Keep each rostered person’s employment summary complete and current, with the Part 65 certificate type and ratings captured where applicable. A roster name without a backing summary is an unproven qualification.

4

Training-record correlation

The inspector cross-checks the names on the sampled work orders against the §145.163 training records. An employee who performed or approved work but has a lapsed, incomplete, or missing training record generates a §145.163 finding and casts doubt on the affected work. Training must be appropriate to the assigned task, per §145.163(b).

How to pass this step cleanly: Sort training records by employee and align them with signatory names. Anyone still signing work with an expired or undocumented training record is a dual-finding waiting to happen.

5

Supervisor and inspector qualification review

The inspector confirms supervisors meet §145.153 (Part 65 certification for U.S.-based supervisors; English literacy) and inspectors meet §145.155 (familiarity with regulations and inspection methods; proficiency with inspection equipment; English literacy). The roster names are checked against the evidence that supports each qualification.

How to pass this step cleanly: Document the basis for each supervisor and inspector qualification — certificate, experience, training — alongside the roster entry, so the evidence is one click from the name.

6

Hazmat training applicability check

If the station ships regulated articles or supports Part 121/135 hazmat functions, the inspector verifies §145.165 hazmat training exists for the employees performing those functions — either the 49 CFR Part 172, Subpart H program (hazmat employer) or training under the operator’s FAA-approved hazmat program for §121.1001/§135.501 functions.

How to pass this step cleanly: If §145.165 applies to your station, keep the hazmat training certificates indexed and expiration-tracked for the specific employees performing covered functions. The applicability determination stays with your hazmat authority.

See your personnel records the way an inspector will

FileFlo's FAA readiness score reviews your roster, employment-summary, and training documentation and surfaces the personnel findings an FSDO inspector would likely cite — stale rosters, signers off the authorized list, lapsed training — before the surveillance visit. Takes under 10 minutes.

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How §145.161 and §145.163 Connect to the Rest of Part 145

The personnel and training records are one corner of a connected records system. A finding in any adjacent area raises a question over the others.

The rosters at §145.161 and the training program at §145.163 prove that the named people approving your work are qualified and current. The work those people sign is documented under the maintenance-records rule and the Part 43 content standard; the procedures that govern all of it live in the repair station manual. Get any one out of sync and the others inherit the doubt: if a signer is off the roster, every work order they approved is suspect; if their training lapsed, the same; if the manual's revision procedures were skipped, the approved program itself is in question.

For the connected pieces, see FileFlo's Part 145 recordkeeping requirements, the RSQCM (repair station and quality control manual), ratings and capability list records, the QC system, and the §43.9 maintenance-entry requirements the signers on your roster must satisfy. For the EASA dual-release context, see FAA–EASA MAG bilateral repair station records.

Where a Document Intelligence Platform Fits in §145.161 and §145.163 Compliance

FileFlo is a compliance document intelligence platform — a read-only proof layer that sits alongside your maintenance and personnel systems and keeps the records you already have audit-ready. It does not run your repair station, hold your certificate, perform maintenance, or replace your accountable manager, chief inspector, or hazmat authority. It handles the document compliance layer those roles otherwise hold together with spreadsheets and binders.

Specifically for personnel and training, FileFlo classifies inbound documents (employment summaries, certificate copies, training completion records, hazmat certificates) against the right CFR section, keeps the §145.161 rosters reconcilable against the people actually signing work, tracks the §145.163(c) 2-year training-record floor, flags training that is approaching expiration before a signer's record lapses, and assembles a personnel packet organized the way an inspector reviews it — rosters, employment summaries, training, hazmat. It does not decide who is qualified or approve anyone for return to service; those are the station's calls. It makes the evidence for those calls produceable in seconds.

Roster reconciliation against signers

Surfaces any approving signature on a work order that does not map to a name on the §145.161(a)(3) return-to-service roster — the cross-check an FSDO inspector runs first.

Employment-summary completeness

Flags rostered individuals missing a §145.161(a)(4) employment summary, or whose summary does not capture title, experience, scope, and certificate/ratings.

2-year training-record tracking (§145.163(c))

Tracks the retention floor per employee and surfaces training records approaching expiration in a 90/60/30-day queue, before a signer’s training quietly lapses.

Inspector-format personnel packet

Assembles rosters, employment summaries, training records, and any §145.165 hazmat certificates into a surveillance-ready packet organized the way a personnel review proceeds.

FileFlo does not certificate personnel, approve articles for return to service, or run a hazardous materials program. It keeps the personnel and training documents that prove your qualified people are who the certificate says they are — audit-ready, at the moment the inspector asks. Qualification, approval, and hazmat-applicability decisions remain with the repair station and its authorized personnel.

Pricing: Starter $89/month, Professional $299/month. 5-day free trial, no credit card required. See how it works for the Part 145 audit binder an inspector asks for.

Frequently Asked Questions

What does 14 CFR §145.161 require a repair station to keep on its personnel roster?

14 CFR §145.161(a) requires a certificated repair station to maintain and make available, in a format acceptable to the FAA, four things: (1) a roster of management and supervisory personnel that includes the names of the repair station officials responsible for its management and the names of the supervisors who oversee maintenance functions; (2) a roster with the names of all inspection personnel; (3) a roster of personnel authorized to sign a maintenance release for approving a maintained or altered article for return to service; and (4) a summary of the employment of each individual on those three rosters, containing enough information to show compliance with the experience requirements of Part 145. The summary must include present title, total years of experience and the type of maintenance work performed, past relevant employment with employer names and periods, scope of present employment, and the type of mechanic or repairman certificate held and its ratings, if applicable. Note the section heading is 'Records of management, supervisory, and inspection personnel' — the older 'total number of employees' phrasing some operators still cite was revised out when the personnel subpart was amended.

How quickly must the §145.161 roster be updated when someone is hired, terminated, or reassigned?

Within 5 business days of the change. 14 CFR §145.161(b) states that the rosters required by the section must reflect changes caused by termination, reassignment, change in duties or scope of assignment, or addition of personnel within 5 business days of the change. This is one of the most-missed deadlines in Part 145 surveillance: a shop promotes a technician to supervisor, loses an inspector, or adds a return-to-service signer and the roster lags. When an FSDO inspector cross-checks the people who actually signed recent work orders against the current roster, anyone signing who is not on the authorized return-to-service roster — or any roster name no longer employed — is a §145.161(b) finding.

Is a Part 145 employee training program required to be approved by the FAA?

Yes. 14 CFR §145.163(a) requires a certificated repair station to have and use an employee training program approved by the FAA that consists of initial and recurrent training, and an applicant for a repair station certificate must submit a training program for approval as required by §145.51(a)(7). The program must ensure each employee assigned to perform maintenance, preventive maintenance, alterations, and inspection functions is capable of performing the assigned task (§145.163(b)). The repair station must document the individual employee training in a format acceptable to the FAA, and those training records must be retained for a minimum of 2 years (§145.163(c)). Revisions to the training program must be submitted to the responsible Flight Standards office in accordance with the procedures required by §145.209(e) (§145.163(d)).

How long must Part 145 employee training records be kept?

A minimum of 2 years. 14 CFR §145.163(c) requires a certificated repair station to document the individual employee training required under §145.163(a) in a format acceptable to the FAA, and to retain those training records for at least 2 years. That is the training-record clock specifically. It is independent of the §145.219 maintenance-recordkeeping rule, which is the separate 2-year retention requirement for the station's work documentation. In practice many shops keep training records for the full duration of employment plus several years, because an inspector who finds that a mechanic who signed off a work order had a lapsed or undocumented training record can cast doubt on the affected work itself — so the training file is part of defending the work, not just a standalone obligation.

Who is allowed to approve an article for return to service at a Part 145 repair station?

For a repair station located inside the United States, 14 CFR §145.157(a) requires that personnel authorized to approve an article for return to service be appropriately certificated as a mechanic or repairman under Part 65. For a repair station located outside the United States, §145.157(b) requires that such a person be trained in, or have 18 months of practical experience with, the methods, techniques, practices, aids, equipment, and tools used to perform the maintenance, preventive maintenance, or alterations, and be thoroughly familiar with the applicable regulations and proficient in the use of the various inspection methods. In all cases, §145.157(c) requires that the person understand, read, and write English. The names of everyone in this category must appear on the return-to-service roster required by §145.161(a)(3).

Do Part 145 employees need separate hazardous materials training?

It depends on what the station and its employees actually do. 14 CFR §145.165(a) requires a repair station that meets the definition of a hazmat employer under 49 CFR 171.8 to have a hazardous materials training program that meets the requirements of 49 CFR Part 172, Subpart H. Separately, §145.165(b) provides that a repair station employee may not perform or directly supervise a job function listed in §121.1001 or §135.501 for a Part 121 or Part 135 operator — including loading aircraft — unless that person has received training in accordance with that operator's FAA-approved hazardous materials training program. So a shop that ships components, handles regulated articles, or supports air carrier hazmat functions takes on training obligations that flow from 49 CFR, not just from Part 145. FileFlo can index and track expirations on those certificates, but the program content and the function-by-function applicability call belong to the station's hazmat authority.

What supervisory and inspection qualifications does Part 145 require, and where are they documented?

Supervisory requirements are in §145.153: the station must maintain enough supervisors to direct the work, and a supervisor located in the United States must be certificated as a mechanic or repairman under Part 65 (a supervisor outside the U.S. must have at least 18 months of practical experience or be trained in or thoroughly familiar with the relevant methods). Inspection requirements are in §145.155: persons performing inspections must be thoroughly familiar with the applicable regulations and with the inspection methods, techniques, practices, aids, equipment, and tools used to determine airworthiness, and proficient in using the inspection equipment and visual aids appropriate to the article. Both supervisors (§145.153(c)) and inspectors (§145.155(b)) must understand, read, and write English. The roster and employment summaries required by §145.161 are where the station documents that these named individuals meet those qualifications — the roster is the evidence layer for the personnel rules.

What is the difference between the §145.161 personnel records and the §145.219 maintenance records?

They are two different record sets that an inspector reviews side by side. The §145.161 records are about people — the management, supervisory, inspection, and return-to-service rosters plus the employment summaries that prove each named person meets the Part 145 experience requirements. The §145.219 recordkeeping records are about work — the station's documentation demonstrating compliance with Part 43 for each article it maintains, retained for at least 2 years from the date the article was approved for return to service. The two intersect during surveillance: the inspector pulls work orders (§145.219), reads the approving signatures, and then verifies each signer appears on the authorized return-to-service roster (§145.161(a)(3)) and has current training (§145.163). A gap on either side weakens the other.

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